The Supreme Court has ruled that a belated amendment to a plaint under Order VI Rule 17 of the Civil Procedure Code cannot be rejected merely because it is filed late, provided the additional facts and reliefs sought have a direct nexus with the existing controversy already before the court. The court emphasised that amendments serving the cause of justice and avoiding multiplicity of litigation should ordinarily be allowed, as long as they do not introduce an entirely new or inconsistent case.

Order VI Rule 17 CPC governs amendment of pleadings. The proviso added by the 2002 Amendment Act introduced a significant restriction: after the commencement of trial, a court shall not allow amendment unless it is satisfied that despite due diligence, the matter could not have been raised before. This proviso was intended to prevent frivolous, dilatory amendments that delay resolution.

However, the Supreme Court's ruling refines this position. The key principle is the 'direct nexus' test: if the proposed amendment introduces facts or reliefs that are intrinsically connected to the core controversy already before the court, rejection solely on the ground of belatedness is impermissible. The amendment must not substitute or abandon the original cause of action — it may elaborate, supplement, or clarify it.

The underlying policy rationale is dual: (1) courts must decide all real controversies between parties in a single proceeding to prevent multiplicity of suits, and (2) technical procedural rules should not defeat substantive justice. The distinction the examiner tests is between an amendment that introduces an entirely new cause of action (not permissible post-trial without strong justification) versus one that supplements the existing pleading with related facts (generally permissible if nexus exists). Leading precedents include Revajeetu Builders v. Narayanaswamy (2009) and L.J. Leach & Co. v. Jardine Skinner & Co. (1957), which together establish that courts enjoy wide discretion to allow amendments that serve justice without causing irreparable prejudice to the opposite party.